Climate Lobbying Index

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Indra’s disclosures largely focus on general climate-strategy oversight but provide only limited insight into how any lobbying or policy-advocacy activity is governed. The company states that it "is not aware of having collaborated with any type of organisation whose objective could be understood to be political influence" and that, when it does interact with governments or associations, "it is careful to ensure that their lobbying activities conform to the same principles of cooperation and transparency that are set out in Indra’s own Code of Ethics and Legal Compliance." This reference shows an intention to align any engagement with internal ethical standards, but there is no accompanying description of a formal monitoring or review procedure that would demonstrate how such alignment is checked in practice. Oversight bodies that are well described for climate strategy—the Board, Sustainability Committee and Chief Strategy Officer—are not explicitly tasked with reviewing lobbying consistency, and the company “is committed to complying with the legislation in force regarding transparency of lobbying activities,” which points to legal compliance rather than an internal governance mechanism. No information is provided on systematic reviews of trade-association positions, criteria for joining or exiting associations, board sign-off on advocacy positions, or publication of a lobbying-alignment report. Consequently, while there is a stated commitment to keep any lobbying in line with the Code of Ethics, the absence of detailed processes, responsible parties, or evidence of active monitoring indicates only limited governance over climate-related lobbying activities. View Sources	1

Overall Assessment

Analysis

Score

Limited

Indra’s disclosures largely focus on general climate-strategy oversight but provide only limited insight into how any lobbying or policy-advocacy activity is governed. The company states that it "is not aware of having collaborated with any type of organisation whose objective could be understood to be political influence" and that, when it does interact with governments or associations, "it is careful to ensure that their lobbying activities conform to the same principles of cooperation and transparency that are set out in Indra’s own Code of Ethics and Legal Compliance." This reference shows an intention to align any engagement with internal ethical standards, but there is no accompanying description of a formal monitoring or review procedure that would demonstrate how such alignment is checked in practice. Oversight bodies that are well described for climate strategy—the Board, Sustainability Committee and Chief Strategy Officer—are not explicitly tasked with reviewing lobbying consistency, and the company “is committed to complying with the legislation in force regarding transparency of lobbying activities,” which points to legal compliance rather than an internal governance mechanism. No information is provided on systematic reviews of trade-association positions, criteria for joining or exiting associations, board sign-off on advocacy positions, or publication of a lobbying-alignment report. Consequently, while there is a stated commitment to keep any lobbying in line with the Code of Ethics, the absence of detailed processes, responsible parties, or evidence of active monitoring indicates only limited governance over climate-related lobbying activities.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Indra Sistemas provides only limited insight into its climate-related lobbying. The company discloses that it has "engaged with the EU Non-Financial Reporting Directive, in particular climate-related reporting using the TCFD framework," identifying one specific policy focus, but it does not mention any other climate laws or regulations. It explains the objective of this engagement, stating that it "would like climate-related reporting to be mandatory for all companies, incentivising them to think about the risks and opportunities of climate change using the TCFD framework," which clarifies a single desired policy outcome. However, the report gives no detail on how this position was communicated—there are no references to letters, meetings, consultation responses, or the policymakers targeted—so the mechanisms and targets of its lobbying remain undisclosed. This narrow scope and absence of procedural detail result in only a basic level of transparency about the company’s climate lobbying activities.	1

Indra Sistemas SA

Lobbying Transparency and Governance